Two years on from the Digital Services Act’s full implementation, our Data & Technology team looks at recent developments and what’s to come in 2026. Following a lengthy learning and implementation period for providers, the European Commission and national regulators are now gearing up for enforcement of the Digital Services Act (DSA). Later this year, we expect ‘vetted’ researcher access and the protection of minors to be the focus. Notable developments from year two The first DSA fine Online platform X was fined €120 million for...

The European Banking Authority (“EBA”) has published a new opinion EBA/OP/2026/01 of February 12, 2026 (the “Opinion”), establishing the supervisory expectations and scenarios applicable to crypto-assets service providers (“CASPs”) supplying payment services using electronic money tokens (“EMTs”) once the transitional period ends on March 2, 2026, as established in the EBA’s No Action letter to the national authorities in June 2025 (“No Action Letter,” EBA/Op/2025/08). For more information on the No Action Letter, see our Legal Flash | EBA No Action Letter on the interaction between MiCA and PSD2. In this Opinion, the EBA identifies three...

In this edition of the Neural Network, we look at key AI developments from January and February. In regulatory and government updates, Ireland has announced an AI Bill; South Korea’s extra-territorial AI law has taken effect; and the ICO raises the possibility of data protection law derogations to facilitate AI development. In AI enforcement and litigation news, the European Commission joins Ofcom and the ICO in announcing further investigations into Grok; and a Chinese court has ruled that a service provider...

CROSS BORDER ACQUISIITONS EUROPEAN COMPANIES INVESTING IN THE UNITED STATES Why U.S. Acquisitions Should Be a Core Growth Lever for European Companies European capital has flowed into the United States for more than three centuries, and the U.S. remains the single most important geography for outbound European foreign direct investment, accounting for approximately 40% of all European FDI stock globally. Within that investment, acquisitions—not greenfield builds—have emerged as the dominant entry and expansion mechanism, particularly for companies seeking speed, scale, and local...

On February 10, 2026, the Court of Justice of the European Union (CJEU) confirmed in a landmark judgment that companies can seek annulment of European Data Protection Board (EDPB) binding decisions before the adoption of a final decision by their lead Supervisory Authority (SA). This decision opens the floodgates to substantive review of EU-level General Data Protection Regulation (GDPR) enforcement. It will create dual-track litigation for GDPR sanctions: before the General Court (GC) against EDPB decisions and before national courts, against national...

Many companies have been reconsidering their work-from-home policies in the years since the COVID-19 pandemic forced office closures. While reversing these policies may be straightforward in the United States, the process is far more complex internationally. Understanding international employment law can help ensure a smooth and legally compliant return to the office. Here are key insights. Quick Hits In the United States, non-unionized companies can mandate a return to the office due to at-will employment norms, but this may strain...

As innovations continue to accelerate, the technology landscape in 2026 may reach a turning point, marking a shift from research and development (R&D) to adaptation. This year’s outlook highlights a shift towards smarter, autonomous systems that operate within the physical world. Organizations that embrace this shift may thrive, while those that lag behind may risk losing pace with a rapidly accelerating digital economy. 1. Moving Toward AI Integration Virtually every industry has begun adopting AI, moving from experimentation to practical, integrated...